On June 5, 2019 the U.S. Securities and Exchange Commission (“SEC”) approved a new rule requiring investment adviser firms to provide retail investment clients with a Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3. An SEC registered investment adviser’s initial Form CRS/Form ADV Part 3 must be filed via IARD by June 30, 2020. The ADV Part 3 filing and delivery deadline is July 30, 2020. With this fast approaching deadline, investment advisers must act now to ensure the Form ADV Part 3 is timely filed and delivered.
Category Archives: ADV Part 3
Compliance with the new Form CRS/Form ADV Part 3 is fast approaching for investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) and certain state securities regulators. An SEC registered investment adviser’s initial Form CRS/Form ADV Part 3 must be filed via IARD by June 30, 2020 and delivered to existing clients no later than July 30, 2020. Click here to read our recent blog on the SEC’s decision to maintain the original June 30, 2020 filing deadline.
Drafting Tips for ADV Part 3/Form CRS
May 20, 2020
Regulatory Update: On June 19, 2020, the Oklahoma Department of Securities withdrew (effective immediately) its notice requiring state registered investment adviser firms to file the Form ADV Part 3/Form CRS. For additional details, please click here. As a result, the following requirements described below are no longer in effect.
Drafting Tips for Form ADV Part 3/Form CRS
May 01, 2020
On June 5, 2019, the U.S. Securities and Exchange Commission (“SEC”) approved a rule requiring investment adviser firms registered with the SEC to provide investment advisory clients who meet the definition of “retail investors” with a Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3. Despite the impact of COVID-19, the SEC has declined to extend the deadline for investment advisers registered with the SEC to file and deliver the new Form ADV Part 3/Form CRS. Click here to read our recent blog on the SEC’s decision to maintain the original June 30, 2020 filing deadline.
On Wednesday, April 22 at 12:00 PM CT, RIA Compliance Consultants will host a webinar entitled, “Preparing the Form ADV Part 3/CRS.” During this webinar, Bryan Hill, President of RIA Compliance Consultants, Inc., will be discussing how to prepare the Form ADV Part 3/Client Relationship Summary for investment adviser firms registered with the U.S. Securities and Exchange Commission. The webinar will be hosted on Zoom.com.
SEC Is Not Extending the Deadlines for RIAs to File/Deliver Form ADV Part 3 Due to COVID-19
April 03, 2020
In response to numerous inquiries and requests for an extension of the deadlines facing SEC registered investment advisers related to filing and/or delivering the Form ADV Part 3/Client Relationship Summary (“CRS”), the U.S. Securities and Exchange Commission (“SEC”) issued a Public Statement on April 2, 2020 indicating that the SEC is not extending the filing and delivery deadline for the Form ADV Part 3/CRS.
Investment Advisers Should Begin Preparations for 2020 Renewals
October 29, 2019
As annual renewal season rapidly approaches, investment advisers should be proactive and begin preparing for renewals by reviewing to make sure the investment adviser is properly registered or notice filed, as applicable, and that its investment adviser representatives are properly licensed with all required state securities regulators. The IARD Renewal Program serves to facilitate the annual renewal of investment advisers and their investment adviser representatives’ registrations with the appropriate state securities regulators. Although, an investment adviser’s registration, notice filing, and licensing requirements are some things that should be reviewed and monitored on an ongoing basis, during the annual renewal process all investment advisers should review their existing registration or notice filing status and each investment adviser representative’s licensing status to confirm that the investment adviser and its representatives are properly registered, notice filed, or licensed (as applicable). Additionally, all state registered investment advisers should also review the state requirements to see if branch office registration is required and, if it is, investment advisers should confirm that all branch office locations have been properly registered.
Form CRS Relationship Summary/ADV Part 3 FAQ Page Live
July 23, 2019
On June 5, 2019 the U.S. Securities and Exchange Commission (SEC) voted on and approved package of rulemakings and interpretations, that includes the new Form CRS Relationship Summary, also known as the ADV Part 3. The ADV Part 3 is designed to be a short and accessible disclosure for retail investors that helps them compare information about firms’ investment advisory offerings. To help investment advisers understand what will be required by the Form CRS Relationship Summary/ADV Part 3, RIA Compliance Consultants created a new webpage, Form ADV Part 3 FAQs. The page features 25 questions with detailed answers about what will be required by investment advisers on the Form CRS Relationship Summary/ADV Part 3.
Form CRS Relationship Summary – ADV Part 3
June 11, 2019
On June 5, 2019 the U.S. Securities and Exchange Commission (SEC) voted on and approved a CRS Relationship Summary also known as the ADV Part 3. The ADV Part 3 is designed to be a short and accessible disclosure for retail investors that helps them compare information about firms’ investment advisory offerings. The relationship summary is intended to inform retail investors about:
